This section is intended to enhance the user’s knowledge and understanding of the elements that comprise a comprehensive and effective ICP. This section provides a thorough description of each of the eight, “core” elements that should be present in any ICP as well as the five, “additional” elements that may warrant consideration from certain enterprises, organizations, or industry sectors. The purpose of each element and the tasks that must be undertaken to implement each element are discussed in detail.
Core Elements of an ICP
- Management Commitment to Compliance
- Organizational Structure and Responsibilities
- Transaction Screening Process and Procedures
- Shipment Control
- Auditing and Internal Review
- Training and Education
- Recordkeeping and Documentation
- Reporting and Corrective Action
The table below provides a brief overview of the "core" elements of an ICP and describes the purpose and considerations applicable to each ICP element.
|Core ICP Element||Purpose and Key Considerations|
|Management Commitment to Compliance||
Purpose: to clarify the enterprise’s policy with respect to strategic trade control; to convey the importance and value placed on effective STC compliance procedures; and to define senior management’s specific compliance expectations.
|Organizational Structure and Responsibilities||
Purpose: to ensure that all compliance-related functions, duties, and responsibilities in your enterprise are clearly identified, defined, and assigned; that the relevant positions and incumbents are known throughout the organization; and that there are internal records of these assignments that are routinely updated and distributed to employees.
Establish an internal organizational structure, responsible for strategic trade control:
|Transaction Screening Process and Procedures||
Purpose: to determine the classification of the commodity to be transferred and whether or not the transaction is subject to trade licensing requirements, restrictions, or prohibitions. This element of an ICP includes:
Purpose: to verify that classification/identification and transaction screening procedures have been completed prior to shipment and to confirm the accuracy and integrity of the shipping declarations. Enterprises must confirm at the time of shipment/transfer that:
|Auditing and Internal Review||
Purpose: to appraise the integrity of your ICP – across the entire enterprise - by verifying that operational compliance procedures are being implemented properly, reflect the enterprise's stated compliance policies, processes, and procedures, and that your enterprise’s procedures are consistent with all relevant STC laws and regulations.
|Training and Education||
Purpose: to provide compulsory, periodic training for all employees that maintain STC compliance or export-related functions, to ensure they possess a working knowledge of current STC obligations and the specific requirements of the ICP.
|Recordkeeping and Documentation||
Purpose: to ensure STC-related documents (administrative and transaction records) are maintained in a consistent manner and can be made available to your government or other external parties for inspections or audits.
|Reporting and Corrective Action||
Purpose: to provide clear guidance to all employees regarding the notification, escalation, and corrective action measures to take in the event of suspected or known incidents of STC non-compliance.
Click on the sub-headings to the left to learn more about each core element of a comprehensive and effective ICP.